In a speech prepared for delivery on September 10, 2019, NCUA Board Member Todd Harper gave a speech at the Women in Housing and Finance Policy Lunch. Of interesting note for compliance professionals - especially those in credit unions regulated by the NCUA - is that Mr. Harper explained that he believes there is a need for improved consumer protection examinations and enforcement.
Specifically, Mr. Harper explained that he has “found that the NCUA’s current method for examining and enforcing consumer financial protection laws and regulations in credit unions with less than $10 billion in assets that it supervises is not comparable to our sister agencies.” He expands on this by saying that “NCUA’s different approach to consumer financial protection reviews runs counter to the congressionally mandated mission of the Federal Financial Institutions Examination Council, which works to “prescribe uniform principles, standards, and report forms” across all types of financial institutions.”
Mr. Harper then proceeds to explain that the NCUA used to conduct full consumer financial protection compliance reviews as part of its examination program, but the agency has significantly shifted its focus to safety and soundness enforcement in recent years. Mr. Harper then states that he believes “the NCUA should evolve its approach to consumer financial protection. We should also increase guidance to the credit union system to improve compliance with consumer financial protection laws.”
Whether or not this speech is a foreshadow of things to come for credit union compliance enforcement remains to be seen. However, credit union compliance officers should review this speech and evaluate needs for improvements to their applicable Compliance Management System to ensure they are ready for any changes in compliance enforcement that may come in the future.
View Mr. Harper’s speech here.
